Labor Community Advocacy Network

to Rebuild New York


Public Comment on LMDC Partial Action Plan No. 10

Lower Manhattan Development Corporation

One Liberty Plaza 20th Floor

New York, NY 10006


October 26, 2005


Dear Members of the Board of the Lower Manhattan Development Corporation:


We appreciate this opportunity to comment on the Proposed Partial Action Plan No. 10. Of the $2 billion in Community Development Block Grant (CDBG) funds allocated by United States Department of Housing and Urban Development to the Lower Manhattan Development Corporation (LMDC), approximately $800 million remains.


We would like to thank the LMDC for holding its first public hearing in March on the use of these funds.  We are pleased to see some of what the public called for at that hearing is reflected in this PAP including community amenities in Chinatown and along the East River Waterfront.  Compared to previous allocations of LMDC resources, we are especially pleased to see a portion of these funds go to these low-income neighborhoods. And we are pleased that the thrust of these expenditures is on strengthening neighborhoods, and community-level economic development that helps balance and fill out some of the mega-projects being undertaken in Lower Manhattan.


Overall PAP#10 is a welcome departure from previous proposals and we offer the following comment:



1) Chinatown

We are pleased that $5.4 million is proposed for the “Chinatown Clean Streets Program.” There is little doubt that residents, employees and visitors will benefit from a comprehensive community initiated plan to help elevate excessive garbage that too often piles up on Chinatown’s streets.


To guarantee the long-term benefits from this plan, more details should be made public about the transfer of the clean streets program from the city expected in 2009 to the community.  How the program continues is a matter of great significance to the city and to the local community, and should be subject to timely public input.


We are concerned about the proposal that, after the LMDC funds run out, an option discussed for sustaining the program is a Business Improvement District (BID).

BIDs have a long and controversial history in New York. They provide services that ought to be provided by the city, but they provide them only in areas where local landlords pay for them. As a result, pressure for the city to provide services declines, leaving the areas with BIDs overcharged and areas without them underserved. In addition, BIDs are by mandate controlled by landlords—a very narrower segment of the overall community. The city is responsive to voters, a much broader segment. Finally, BIDs have typically paid its employees very low wages with little in the way of benefits, training, or opportunities for advancement. This is highly problematic, since these are jobs that would otherwise be good, unionized jobs for city workers.


2) East River Waterfront

The East River Waterfront projects as they have been presented to the public are very encouraging. We are pleased to note, as well, that this plan has significantly improved through engagement with the affected community. Done right, these improvements will encourage visitors and businesses to Chinatown and the Lower East Side, and will improve the quality of life for local residents.


The plan calls for pavilions under the FDR Viaduct with “a variety of retail, cultural and/or community uses to complement the public open space experience.” This is one of the more appealing parts of the plan. Yet how it is done is of great importance.


First, there must be real assurance that the pavilions can be designed in a way that they are not overly noisy, and that there are not health affects from proximity to such intense exhaust fumes. And the area must be designed so that it is well-lit and populated, to address concerns about crime.


The use of the pavilions is also of great community concern. Community and cultural uses must not take a back seat to retail. Community/cultural uses may also require funding to support the fullest possible programming; options for developing support for these programs should be explored. At the same time, retail should be, as the PAP suggests, oriented to complementing the public open space experience, not to maximizing revenue.

Most of the plan for the East River is highly appealing. Some of the most expensive parts, however, are also the most problematic, since they seem to involve building in or over the water. The park should be built only on dry land.


Finally, it is critically important that the East River Waterfront remain a city park, and not a public authority or private “trust.” Maintenance should be done by city workers, the park should be within the city parks system, there should not be a new entity set up to own or operate the park.


LMDC resources – or any use of taxpayer funds – should be used to foster an environment that creates good paying jobs with benefits.  Doing otherwise, means workers too often rely on publicly funded programs like food stamps and public hospitals.


Transparency at authorities or private trusts is slim, which makes it difficult to monitor the usefulness of the funds and condition and wages of the employees.


3) Hudson River Park Trust

LCAN and GJNY reluctantly and regretfully oppose the use of $70 million for the Hudson River Parks Trust. To describe this wealthy and well visited area of Manhattan as “blighted, unhealthy, unsanitary and dangerous,” is simply false as census data and a visit to the HRPT would show.


While access to public space and the Hudson River is more than just an amenity, this proposal has several fatal flaws. Most important, it entails building in and over the river, creating irreparable damage to the environment.


In addition, the park is maintained by clients of the Doe Fund.  Since these workers are not directly employed by the city and historically this type of work does not offer sustaining wages, we urge the LMDC to require that the funds associated with this proposal support living wage jobs salaries that are at parity with the parks department and that include benefits.  Employees of the Parks Department that do similar work as that is done by Doe Fund workers have better wages, job security and benefits than those working for the HRPT. At a minimum, the HRPT should be required to report to the LMDC ranges of its wages and the types of jobs it has created on a regular basis. It is counterproductive to use tax-payer resources for jobs that do nothing to lift workers out of poverty like conditions.


And finally, the HRPT, because it is a “trust,” is not subject to the normal transparency and public control. This makes it impossible for the city to maintain standards of equity when one project can command resources from many directions at the same time as regular city parks languish.



4) East Side K-8 School

We applaud the LMDC for its proposal to provide $20 million for an elementary school in Lower Manhattan.  The growing population in the area, even prior to 9/11, deserves better access to education. 


We are curious however, to learn more details about how the use of Liberty Bonds will help finance the development.  In fact, in comparison to other PAP’s, $20 million seems on the smaller side of what we would have hoped to see the LMDC invest in a project like this.


5) Lower Manhattan Ferry Service

In different formats, New Yorkers have expressed interest in expanding ferry service in Lower Manhattan.  For example, ferries can help commuters in Brooklyn and facilitate commuting from the east to west side of Lower Manhattan, something that can be quite arduous.  While expanding ferry service between Westchester and Rockland Counties is eventually a worthy goal, we are unclear why these communities have taken precedence over New York City transportation needs.



It seems questionable to spend limited 9/11 resources on “to help make the New York Stock Exchange Area a competitive location for businesses.”  Addressing appropriate security concerns in a way that is not overly intrusive seems like a worthwhile way to spend rebuilding funds. But finding a way to eliminate guards with machine guns and body armor would seem a higher priority than creating a fountain.


7) Splendor of Florence

A huge backlog of applications for cultural projects is sitting at the LMDC headquarters, with hundreds of projects submitted at the request of the LMDC over the course of almost four years. It is hard to imagine how the “Splendor of Florence” festival rose to a level of urgency that trumped all these other projects to get funding.


What is needed is a clear and professional process for evaluating the proposals and choosing the best ones. The Governor Pataki and Mayor Bloomberg have proposed that $45 million be set aside for a grantmaking program for off-site arts & culture, and another $45 million for community enhancements to make the area more livable for residents, more workable for businesses, and more attractive for visitors.


It is in this context that projects like the Splendor of Florence should be evaluated. In the absence of a clear and professional process, it is impossible to avoid charges of cronyism and mismanagement. There is no mystery to how to administer a grantmaking process: dozens of foundations in New York do it every day. A grant at this stage to the Splendor of Florence fails the most basic test of fair and professional grantmaking.


8) Affordable Housing

Beyond the LMDC’s announcement of $50 million for the development of affordable housing over two years ago – long listed as a top priority by New Yorkers, including at the LMDC’s  March forum – this PAP does not address the affordable housing crisis in Lower Manhattan. The $50 million proposal should be finalized quickly, and every effort should be made to devote substantial additional funds to this effort.






David Dyssegaard Kallick                                             Bettina Damiani

Coordinator                                                                  Director

Labor Community Advocacy Network to                     Good Jobs New York